The estate of Carl Pohlad filed a petition with the U.S. Tax Court on Tuesday because the estate disagrees with the IRS as to how much Pohlad's interest in the Twins is worth.

Pohlad owned a non-voting 52.2% interest in MT Sports LLC, which in turn owned a 99% non-voting interest in Minnesota Twins LLC (i.e., the team). Pohlad also owned 95.5% interest (10% of the voting shares and 100% of the non-voting shares) in Twins Sports Inc., which owns 100% of the voting interest in Minnesota Twins LLC. The other 90% of the voting shares in Twins Sports was held by his three sons.

Pohlad's estate valued his entire interest in the team at $24 million. The IRS valued it at close to $300 million.

You're not going to find this online right now unless you have access to Westlaw or something. Maybe Deadspin will pick it up.

The estate of Carl Pohlad filed a petition with the U.S. Tax Court on Tuesday because the estate disagrees with the IRS as to how much Pohlad's interest in the Twins is worth.

Pohlad owned a non-voting 52.2% interest in MT Sports LLC, which in turn owned a 99% non-voting interest in Minnesota Twins LLC (i.e., the team). Pohlad also owned 95.5% interest (10% of the voting shares and 100% of the non-voting shares) in Twins Sports Inc., which owns 100% of the voting interest in Minnesota Twins LLC. The other 90% of the voting shares in Twins Sports was held by his three sons.

Pohlad's estate valued his entire interest in the team at $24 million. The IRS valued it at close to $300 million.

You're not going to find this online right now unless you have access to Westlaw or something. Maybe Deadspin will pick it up.

Putting that together and actually sorting out who owned what percentage of what and for what purpose is not something my brain is capable of right now. He might have been the only one who knew.

Putting that together and actually sorting out who owned what percentage of what and for what purpose is not something my brain is capable of right now. He might have been the only one who knew.

Closely held, with he and his sons the only ones owning shares, does it really matter? He may not have had unfettered "control", but most of the profits went to him. It's just another example of the BS that owners the spout about losing money.

Closely held, with he and his sons the only ones owning shares, does it really matter? He may not have had unfettered "control", but most of the profits went to him. It's just another example of the BS that owners the spout about losing money.

And probably to the Pohlad's too. Tax loopholes are probably why they did it so complicatedly.

Oh, I'm sure the Pohlads will claim all sorts of nonsense like valuation discounts for minority interest, lack of marketability, etc. (the tax court petition did make the argument that there was no ready market for the ball club). But as a tax guy I will tell you that substance (closely held business with control nominally in the hands of the sons) can sometimes trump form. It just remains to be seen if this is one of those instances.